BALWANT LAXMANJI PUROHIT,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

ITA 8453/MUM/2025Status: DisposedITAT Mumbai12 March 2026AY 2018-2019Bench: SHRI OM PRAKASH KANT (Accountant Member), MS. KAVITHA RAJAGOPAL ( (Judicial Member)11 pages
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What did the Tribunal hold?

The Tribunal held that additions made solely on the basis of statements recorded during a search, without corroborative material and without providing the assessee an opportunity to cross-examine deponents or access the material, are unsustainable in law.

What were the facts?

A search operation on the 'Rubberwala Group' revealed data suggesting the assessee paid 'on-money' in cash for a property. The Assessing Officer made additions based on statements recorded during the search.

What were the issues?

Whether additions can be sustained based on statements from a search without providing the assessee with supporting material and cross-examination opportunities. Whether a combined satisfaction note for multiple assessment years is valid.

Which sections of the Income-tax Act were involved?

Section 132,Section 153C,Section 69

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, MUMBAI BENCH “B” MUMBAI

Before: SHRI OM PRAKASH KANT & MS. KAVITHA RAJAGOPAL

For Appellant: Mr. Arun Kanti Datta, CIT-DR
Pronounced: 12/03/2026

PER BENCH

The captioned appeals have been preferred by the assessee challenging the order dated 11.10.2025 of the Ld. Commissioner of Income-tax (Appeals) – 52, Mumbai [in short ‘the Ld. CIT(A)’] passed

Balwant Laxmanji Purohit ITA No. 8452 to 8454/MUM/2025

order u/s 250 of the Income order u/s 250 of the Income-tax Act, 1961 (in short ‘the Act’) tax Act, 1961 (in short ‘the Act’) pertaining to assessment year 2017 assessment year 2017-18 to 2019-2020 respectively. 2020 respectively.

The order continues below.

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